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Privacy Policy – Sustainability Works Ltd. Privacy Policy Introduction This is the Privacy Policy of Sustainability Works Ltd. (“Sustainability Works”) of 39 Colpe Park, Deepforde, Drogheda, Meath, A92 FW4A (hereby referred to as “us” and “we”). The purpose of this Privacy Policy is to ensure that individuals understand how we process their information. Sustainability Works endeavours to comply with the General Data Protection Regulation, Data Protection Acts, ePrivacy Regulation and data protection best practices. This Policy informs individuals how Sustainability Works processes personal data in accordance with the principles of data protection identified in data protection legislation. We will process any personal information provided to us by individuals, whether it be provided through our website (www.sustainabilityworks.ie), by any form, correspondence, telephone, email or by any other means, or otherwise held by us in relation to you in the manner set out in this policy. By submitting your information to us and or by using the website you confirm your consent to the use of your personal information as set out by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the website or provide us with any personal information. Information collected by us Sustainability Works provide consultancy, guidance and support concerning sustainability for business, communities, public bodies and the public at large, depending on the needs of our clients. We may collect, use and store (process) the following categories of personal data: • Information necessary to reply to any query you may put to us and or provide services at your request. Such personal data includes a data subject’s name, address, phone number, email address and role in an organisation (if contacting us as part of their work or employment). • Information necessary in order to facilitate, process, deliver, bill or charge monies for an agreed business transaction (e.g., name, payment details, etc.) • Information you provide to us by filling out any forms on the website or by way of emailing us. • Records of correspondences whether by email, telephone, through any form on our website or by any other means, • Information you provide to us in person. • Details of any business or commercial activities or transactions you carry out with us, whether through email, the website, telephone, or by any other means. • Details of your visits to our website including traffic data, location data, weblogs and other communication data in accordance with our Cookie Policy www.sustainabilityworks.ie that may identify personal information (e.g., cookies) and non-personal information (e.g., information of an anonymised or technical nature). How we use your personal information We may use your personal information for the purposes of: i. Processing any enquiry requested by you; ii. Entering into and or completing any sales, recruitment or training services as requested by you; iii. Setting up, operating and managing any account or line of credit, if applicable; iv. Setting up, operating and managing any marketing and or fundraising services subject to your explicit consent (please see Marketing & Fundraising below); v. Complying with our legal duties and responsibilities; vi. Debt collection and the collection of outstanding monies; vii. Providing, monitoring, reviewing and supporting our online presence via our website and social media (please see our Cookie Policy www.sustainabilityworks.ie viii. Monitoring any billing or credit transactions for the purpose of preventing fraud; ix. Provision of security to, and ensuring the health and safety of, employees and or visitors to company offices. Sustainability Works may on occasion, and on a case-by-case basis, process some health and or medical data in order to make reasonable accommodation under equality legislation and or the Employment Equity Acts. We would only do so with explicit consent from a data subject and only for the purposes of making reasonable accommodation. Such data will be destroyed or deleted once is it no longer necessary (in accordance with our data retention policy). Sustainability Works does not engage in any automated decision-making processes, nor do we use any personal data as a basis for any such automated decisions. Sustainability Works does not transfer personal data outside the EU or outside the jurisdiction of the General Data Protection Regulation. However, Sustainability Works may use some external services providers to provide business functions. For example, should you consent to the use of your information for marketing then we may use Mailchimp to send you marketing emails (discussed below). Some of these service providers may be located outside the EU or EEA. In such cases, personal data is protected by use of binding corporate rules or EU-US privacy shield to ensure continued compliant with the General Data Protection Regulation and uphold the privacy rights of all data subject. Some of these service providers may be located within another EU member state, and any that are, are subject to the One Stop Shop Mechanism as identified by the Irish Data Protection Commission. For more information about binding corporate rules, EU-US Privacy Shield and the One Stop Shop Mechanism please visit the Data Protection Commission website at www.dataprotection.ie Marketing & Advertising Policy As a private company, Sustainability Works sometimes engages in marketing and advertising to increase awareness of our brand and encourage the use of our services. In terms of data processing, subject to your explicit consent, we may use your personal information for the purpose of: i. Marketing and Sales promotions; ii. Providing you with information about promotional offers on our products and services; iii. Carrying out any client research, survey and analysis; At some interactions with Sustainability Works you may be asked to consent to your data being used for marketing and or advertising purposes. In such cases, consent will require a positive action on your part. For example, on a client form you would have to tick a box stating that you consent to your data being processed for marketing and or advertising purposes. Sustainability Works is committed to privacy by design and privacy by default. As such, you will never have to ‘opt-out’ of our marketing or advertising processes; you will only ever have the option of ‘opting in’ if you’d like to be included. We do not engage in ‘pre-ticked’ boxes on consent forms, nor do we ever assume you would consent to your data being processed. You are free to withdraw consent for any marketing and or advertising related matters at any time you want. Social Media Sustainability Works engages in a number of social media services, and we strive to uphold privacy rights online. However, sometimes members of the public may post something objectionable and beyond our control to Sustainability Works’ social media pages/forums. In such cases, we will act to rectify any difficulties as soon as we are notified or become aware of the problem. We do not provide a continuous monitoring of social media sites/forums so there may be a slight delay from the initial post to when become aware of a problem. Sustainability Works may on occasion hold marketing or fundraising events in which members of Sustainability Works and the general public may be present. Such events are often held at public locations such as a trade show or launch event. Sometimes we may wish to take a photograph at such events to promote our brand or event on social media. In such cases, it is our policy for our photographer/social media handler to announce their presence and provide additional instructions and assistance. However, we do not have any control over private individuals or their social media accounts, and we cannot stop members of the public from posting pictures of events online without the consent of all participants. For information relating to social media usages, cookies or widgets, please see our Cookie Policy www.sustainabilityworks.ie Information Storage We will take reasonable steps to ensure that personal data is kept secure and protected, including but not limited to, electronic data being protected using appropriate software, relevant networks safety and security checks, and, where applicable, physical data is stored in a physically secure environment with restricted access to only those employees who require access to the data in order to complete any tasks or functions. We have a general data retention policy that relates to the retention of relevant data for seven years. Personal data that is no longer required will be destroyed and or deleted in a secure manner. We do not process personal data that is not required nor necessary for any of our stated purposes. Disclosure of data We may outsource certain commercial functions to external third parties, e.g., debt collection, accounting auditors, etc. and in such cases where your personal data is required for the purposes of completing those functions then an appropriate data processing agreement, with relevant safeguards, will be in place to ensure our ongoing obligations under GDPR is upheld. We may also have to disclose certain personal data in accordance with any legal obligation imposed on us. Any such disclosure would be in accordance with the law, e.g., disclosed on foot of a court order, etc. Requesting your data Any person has the right to find out whether an organisation has any personal data about them, what they use the personal data for and ask for copies of personal information held by that organisation. If you wish to make a data access request in order to get a copy of any personal data we may process, please write a letter stating that you wish to make a data access request and address it to: Data Protection Sustainability Works 39 Colpe Park Deepforde Drogheda Meath A92 FW4A Or email info@sustainabilityworks.ie. In order to process your request, we may request that you send us a copy of your identification (passport, drivers licence, etc.). The reason we ask for personal identification is to ensure that you are the correct person making the request for your personal data. Unfortunately, verbal access request requests cannot be entertained. In response to any data access request, you have the right to refer the matter to the Data Protection Commission if you are unhappy with the outcome, however, we ask that you notify us first of any issue so that we may help resolve it as quickly as possible. Rectifying mistakes You have the right to rectify any incorrect or inaccurate personal data at no cost to you. If you believe that we are incorrectly processing any of your personal data, please inform us by emailing info@sustainabilityworks.ie. Queries or complaints If you have any queries or complaints regarding our Privacy Policy or any data protection matter, please let us know by emailing info@sustainabilityworks.ie. Individuals have the right to refer any matter to the Data Protection Commission by contacting them at www.dataprotection.ie or by writing to: Data Protection Commission 21 Fitzwilliam Square South Dublin 2 D02 RD28 Ireland If you are, for whatever reason, considering contacting the Data Protection Commission about us we would ask that you inform us of your difficulty first so that we can try to resolve it to your satisfaction. Changes to our Privacy Policy Any changes we may make to our Privacy Policy in the future will be posted on the website. Any changes will become effective upon posting the revised Privacy Policy on the website. If we make any material or substantial changes to this Privacy Policy, we will use reasonable endeavours to inform you by email, notice on the Website or any other agreed communications channels. Privacy Policy last reviewed: October 2021 /END